The Agricultural Produce Marketing Committee, Bangalore vs The State of Karnataka & Ors.
Background
In the 1990s the Karnataka government acquired roughly 172 acres and separately about 100 acres of land in Bangalore, owned by the Jamanlal Bajaj Seva Trust, to build a mega-market for the Agricultural Produce Marketing Committee (APMC), Bangalore. The acquisitions were repeatedly litigated and delayed by stay orders, disputes over whether the land was "excess" land under the Karnataka Land Reforms Act, and disputes over possession and compensation. After the Right to Fair Compensation and Transparency in Land Acquisition Act, 2013 came into force, the landowners argued the acquisitions had lapsed under its Section 24(2) (which deems an old acquisition lapsed if neither possession nor compensation was completed for five years). A single judge of the Karnataka High Court agreed and held the acquisitions lapsed, deciding only that one issue and leaving several other disputed points (validity of the original 1894-Act notifications, legality of possession, etc.) undecided; the Division Bench affirmed. The APMC appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that the High Court's ruling could not survive in light of the Constitution Bench's subsequent decision in Indore Development Authority v. Manoharlal (2020) 8 SCC 129, which had overruled the earlier Pune Municipal Corporation line of cases and clarified that "or" in Section 24(2) between "possession" and "compensation" must be read as "nor"/"and", meaning a lapse occurs only if BOTH possession was not taken AND compensation was not paid for five years; if either one occurred, there is no lapse. Since this settled position contradicted the basis on which the High Court had ruled, the Supreme Court set aside the finding of lapse. However, because the High Court (both the single judge and Division Bench) had wrongly decided the case on this one ground alone without adjudicating the several other substantive issues that were raised (validity of the acquisition notifications, legality of the possession taken, etc.), the Supreme Court held it had "no other alternative" but to remand the matter back to the single judge to decide all the remaining issues afresh within twelve months, expressly refraining from expressing any opinion on those other issues.
Lesson Learnt
Courts deciding a case with multiple framed issues should adjudicate all of them rather than disposing of the matter on a single convenient ground, because if that one ground is later overturned on appeal, the entire case must be sent back for a fresh decision on everything else, wasting years of litigation; separately, a claim that a land acquisition has "lapsed" under the 2013 Act's Section 24(2) fails unless BOTH possession was never taken AND compensation was never paid for five years or more.